CIC rejects blanket fiduciary exemption for PMRBP selection records under RTI Act
- Case
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- Bench
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- Citation
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- Statutes
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- SCC Times
The Central Information Commission held that a fiduciary relationship is not established merely by holding information confidentially or as part of an internal process. It directed disclosure of nomination status and aggregate statistics for PMRBP selection records, rejecting a blanket exemption under the Right to Information Act, 2005.
Ratio Decidendi · Legal Principle Established
A fiduciary relationship, for the purpose of exemption under the Right to Information Act, 2005, cannot be established solely on the basis that information is held confidentially or is part of an internal process. Mere custody of evaluated records does not, by itself, create such a relationship.
Practice & Procedural Impact for Advocates
Advocates should argue against blanket claims of fiduciary exemption under the RTI Act where the relationship is not clearly defined beyond mere confidentiality or internal process. Litigants seeking information on selection processes may be able to obtain nomination status and aggregate statistics, even if individual evaluation details remain protected.
Key Legal Takeaways
- 1Confidentiality alone does not create a fiduciary relationship under the RTI Act.
- 2Internal process information is not automatically exempt under fiduciary grounds.
- 3Public authorities must disclose nomination status and aggregate statistics for selection processes.
The Legal Issue
The Central Information Commission (CIC) addressed whether selection records, specifically those pertaining to the Prime Minister's Research Fellowship (PMRBP), could be withheld under the Right to Information Act, 2005, by claiming a blanket fiduciary exemption. The core question was whether the mere confidential nature of information or its inclusion in an internal process automatically established a fiduciary relationship, thereby exempting it from disclosure.
Court's Reasoning
The Central Information Commission rejected the argument for a blanket fiduciary exemption. The Commission clarified that a fiduciary relationship is not automatically established simply because information is held confidentially or forms part of an internal selection process. The CIC emphasized that the mere custody of evaluated records does not, by itself, create such a relationship. This reasoning implies that for a fiduciary exemption to apply, a more substantial and defined relationship of trust and confidence, beyond routine confidentiality, must exist.
What Follows
The Central Information Commission directed the disclosure of specific information related to the PMRBP selection records. This includes the nomination status of candidates and aggregate statistics concerning the selection process. The decision mandates that public authorities cannot use a general claim of fiduciary relationship to deny access to such information under the Right to Information Act, 2005.